580.7A3/622

The British Ambassador (Lindsay) to the Secretary of State

No. 455

Sir: I have the honour to refer to my note No. 428 of December 3rd2 regarding the Revised Collision Regulations proposed by the International Conference on the Safety of Life at Sea, 1929, and under instructions from His Majesty’s Principal Secretary of State for Foreign Affairs to transmit to you herewith a copy of a memorandum embodying certain suggestions put forward by the Governments of Belgium and Japan and the Netherlands, and by His Majesty’s Government in the United Kingdom for the amendment of the revised text of the regulations proposed at the Conference.

I am to inform you that as the suggested amendments are only such as would appear to be desirable in order to make the intention of the regulations clear or to give formal sanction to existing practices in the interests of safe navigation, and as they would only affect comparatively few vessels of special types, His Majesty’s Government in the United Kingdom would propose that they should be embodied in the Revised Regulations. It is hoped that the United States Government will feel able to concur in the amendments proposed.

The majority of the Governments concerned have already, either directly or indirectly, signified their acceptance of the Revised Regulations and certain Governments have, moreover, intimated their desire to be informed of the date of operation proposed by His Majesty’s Government in sufficient time to enable the adoption of the [Page 904]Revised Regulations to be announced at least six months before they are to become operative. I am to inform you that in the opinion of His Majesty’s Government in the United Kingdom the 1st January 1933 might well be fixed as the date for the simultaneous adoption of the Revised Regulations, including the additional amendments suggested in the enclosed memorandum.

His Majesty’s Government in the United Kingdom hope that the proposed date for bringing the Revised Regulations into force will be agreeable to the United States Government and they would be glad to receive the views of the United States Government on this matter at latest by the 1st March 1932.

I have [etc.]

R. C. Lindsay
[Enclosure]

International Regulations for Preventing Collisions at Sea

Suggested Amendments to the Revised Text Proposed by the International Conference on Safety of Life at Sea, 1929

Naval Vessels.

Article 2.—Proposed by the Government of the United Kingdom of Great Britain and Northern Ireland, that the following addition should be made to the note at the end of this article:—

“and naval vessels in which it is not practicable to carry the second white light referred to in sub-division (b) of this article shall not be required to carry it.”

There was considerable discussion on the Navigation Committee of the International Conference on Safety of Life at Sea, 1929, as to whether certain classes of naval vessels could comply with the new requirement in article 2 (b) of the revised Regulations that vessels of 150 feet or more in length should carry a second steaming light. One delegation was definitely of opinion that the practical difficulties in the way of compliance were such that naval vessels should be exempted entirely from the requirement but this opinion was not pressed, and, with a view to meeting these and other difficulties affecting naval vessels, it was agreed to add the note at the end of article 2, which permits, in the case of naval vessels of special construction, a departure from the requirements of the article as to the position of lights or their range of visibility. The entire omission of the second steaming light would, however, not be in accordance with the note.

Exhaustive trials, which have since been made by His Majesty’s Government in the United Kingdom, have shown that in certain classes of naval vessels, particularly submarines and the older [Page 905]destroyers, the carrying of the second steaming light would endanger the safe navigation of the vessels or would involve very extensive and unduly costly alterations to them. It is believed that the naval authorities of certain other countries also take the view that such vessels could not reasonably be expected to comply with article 2 (b) of the revised Regulations. The amendment now proposed will obviate any difficulty in this respect.

Article 10.—Proposed by the Netherlands Government that to this article should be added a note similar to that proposed by the International Conference on Safety of Life at Sea, 1929, for inclusion at the end of article 2 of the revised Regulations, namely:—

“In naval vessels of special construction in which it is not possible to comply with the provisions of this article as to the position of lights or their range of visibility, those provisions shall be followed as closely as circumstances will permit.”

The Netherlands Government point out that, as the revised article now stands, submarines have to comply with the general requirement that a vessel when under way shall carry a white light at her stern. While it is possible for a submarine to carry the prescribed light, under certain circumstances a light affixed to the very low after-part would be submerged, and for this reason the light is often carried on the turret.

When the matter was under consideration at the International Conference on Safety of Life at Sea, 1929, the original intention was that all the regulations relating to navigation lights should be included in one article (article 2), and in that case the special exception now embodied in article 2 as regards steaming and side lights of naval vessels would have applied also to stern lights. Finally however, in order to avoid renumbering all the articles following the existing article 10, it was decided to retain the original arrangement of the articles, but the Conference omitted to include in article 10 the intended exception in favor of naval vessels. The amendment now proposed will rectify this omission.

Fishing Vessels.

Article 9 (b) and (c).—Proposed by the Government of Japan, that the words “and Korea” should be omitted from the phrase “in the seas bordering the coasts of Japan and Korea,” which appears in paragraph (b) and again in paragraph (c) of article 9.

In explanation of this proposal the Japanese Government state that the phrase is intended to cover the seas washing all the shores of Japan, and they think that the retention of the words “and Korea” may give rise to some doubt as to whether its application is [Page 906]not confined to the seas bordering the coasts of Japan proper and Korea to the exclusion of other parts of the Japanese Empire, such as Formosa and Saghalien.

It will be noted that the proviso of which the phrase in question forms part, only applies to sailing fishing vessels of less than 20 tons gross tonnage.

Pilot Vessels.

Article 15.—Proposed by the Belgian Government that the footnote to this article should be amended so as to commence:—

“Dutch and Belgian steam pilot vessels . . . .”

The Belgian Government explain that they consider it would be useful to introduce for use by Belgian steam pilot boats the same special fog signal as that used by Dutch steam pilot boats which are engaged in the same waters.

The footnote appears to be intended merely to give information as to the distinctive manner in which the steam pilot vessels in question comply with the requirements of article 15 regarding sound signals for steam vessels under way in fog, &c., and no departure from or alteration in the Collision Regulations themselves is involved.

Position of Forward Anchor Light.

Article 11.—Proposed by the Netherlands Government that the words “and not exceeding 40” should be omitted from the second paragraph of this article, which requires the forward anchor light of a vessel of 150 feet or upwards in length to be carried at a height not less than 20, and not exceeding 40, feet above the hull. In support of the amendment, it is stated that, on occasions, a height of 40 feet above the hull is insufficient, presumably because, on vessels with extensive superstructures, the latter would obstruct an anchor light placed 40 feet above the hull and would prevent it from showing all round the horizon.

It is understood that, in practice, the anchor light on vessels having high superstructures is placed at a height of more than 40 feet above the hull, if this is necessary to secure its visibility all round the horizon. The amendment now proposed thus harmonises with existing practice.

Board of Trade, November 1931.

  1. Not printed.